ML18058A983
| ML18058A983 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/15/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18058A230 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9207310106 | |
| Download: ML18058A983 (5) | |
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0~ SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555
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RELATED TO THE INSERVICE TESTING PROGRAM RELIEF REQUESTS CONSUMERS POWER COMPANY PALISADES NUCLEAR PLANT DOCKET NO. 50-255
1.0 INTRODUCTION
The Code of Federal Regulations, 10 CFR 50.55a{g), requires that inservice testing {!ST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to Subsections (a)(3){i), {a){3){ii), or {g){6){i) of 10 CFR 50.55a.
In requesting relief, the licensee must demonstrate that:
{l) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or {3) conformance with certain requirements of the applicable Code edition and addenda is impractical for it~
facility.
These regulations authorize the Commission to grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation {SE).
Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," was issued April 3, 1989, approving all IST relief requests which were being reviewed by the staff if these were not in conflict with positions presented in Attachment 1 of GL 89-04.
The approval of these relief requests was with the provision that licensees review their most recently submitted IST programs and implementing procedures against the positions in of GL 89-04.
Consumers Power Company performed this review and responded to GL 89-04 in a letter dated October 2, 1989.
The letter included a schedule for conformance with the generic letter.
In a submittal dated February 28, 1990, Consumers Power Company provided a revision to the Palisades !ST program incorporating the guidance of GL 89-04, and superseding previous revisions submitted January 18, 1989, and May 17, 1988.
Revisions were submitted March 13~ and June 28, 1991.
The rev~sion submitted June 28, 1991, superseded a11* previous revisions. The latest submittal reflected modifications made during the 1990 refueling outage enabling more complete compliance with Section XI for pump testing. Several relief requests associated with pump testing were, therefore, deleted from the IST program.
The licensee indicates compliance with the GL 89-04 guidance has been achieved.
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PDR ADOCK 05000255
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- 2.0 EVALUATION The staff, with support from our contractor, Brookhaven National Laboratory (BNL) has reviewed the relief requests in the June 28, 1991, submittal.
Evaluations of the new relief requests are provided in the attached Technical Evaluation Report (TER).
The staff has reviewed the TER and concurs with the evaluations and recommendations on the granting of relief, except as specifically discussed below.
A summary of the status of the pump and valve relief request determinations is presented as Table 1 of this Safety Evaluation (SE).
Relief requests which were approved by GL 89-04 as discussed above, and relief requests which conform to a position in Attachment 1 of GL 89-04, have been reviewed but have not been further evaluated in the TER, but are listed in Table 1 of the SE.
Table 1 includes a description of each relief request and the NRC action on the granting of relief.
The licensee should refer to the TER, Section 5.0, for a discussion of IST program action items identified during the review.
The licensee should resolve all the items in Section 5.0 in accordance with the guidance therein.
As necessary, program or procedural changes covered in Section 5.0 should be completed within one year of the date of this SE, or by the end of the next refueling outage, whichever is later.
For relief requests that have been denied, the licensee's testing should comply with the Code requirements or GL 89-04 guidelines within the first quarter after receiving this SE.
If the licensee had additional justification of impracticality to address the reasons for denial of a relief request, a revised relief request should be submitted within the first quarter, as appropriate.
2.1 Relief Request PRR-4 The licensee has requested relief to utilize velocity rather than displacement for vibration monitoring~ but has not provided adequate information for review and evaluation. Section 5.6 recommends revision of the relief request or adoption of Code Case N-465 which has been approved by NRC by reference in Regulatory Guide 1.147.
The TER and Table 1 indicate that this relief request is an open item.
The licensee should treat this as a denial and take actions within the first quarter after receiving this SE.
2.2 Relief Request VRR-2 This relief request relates to testing safety injection tank check valves.
The TER and Table 1 indicate that this relief request is an open item.
It appears that the licensee needs to further review the current testing and provide additional justification fo~ not full-stroke exercising these valves during cold s-hutdown conditions, and to incorporate the testing described in FSAR 6.1.3.1.2.
Because immediate imposition of the Code requirements would be an undue burden without a compensating increase in the level of safety, considering that the current testing provides a level of assurance of the operational readiness of the valves, interim relief is granted pursuant to IO CFR 50.55a(a)(3)(ii) for a period of one year, or until the end of the next
- refueling outage, whichever is later. During the interim, the testing should be reviewed and changes made to the implementing procedures, and the relief request should be revised and resubmitted as necessary.
2.3 Relief Request VRR-17 Technical Evaluation Report, Section 5.23 discusses this relief request, indicating that it is not required.
VRR-17 is a description of the licensee's check valve disassembly and inspection program which does not appear to be in accordance with the guidelines of GL 89-04, Attachment 1, Position 2.
The licensee should review their disassembly and inspection program to ensure it meets the guidelines of Position 2.
The program description should be included in a separate section of the IST program or in an implementing procedure; however, it should not be a separate relief request.
The relief requests listed in Section 5.23 for specific valves which are to be disassembled and inspected are approved per GL 89-04, Position 2, as described in the TER, with provisions as noted; however, this approval is based on the program meeting the guidelines of Position 2 and is subject to NRC inspection (VRR-2 is an exception as noted above).
The NRC is concerned that there are relief requests for a number of check valves which are to be disassembled and inspected.
In some cases, this is stated as one of several options for alternative testing in the relief request.
The NRC considers disassembly and inspection to be a maintenance activity and is not an acceptable alternative when testing can be performed.
Additionally, nonintrusive methods are employed at a number of plants to verify full-stroke at less than full flow.
The licensee should review their entire disassembly and inspection program for IST valves and determine where improvements in the testing can be made, including where nonintrusive testing techniques could be employed.
It is requested, that the results of the licensee's review be provided to NRC within one year of the date of this SE or by the end of the next refueling outage, whichever is later.
2.4 Relief Requests VRR-18, VRR-19, and VRR-24 Interim relief is recommended for three relief requests VRR-19, VRR-18, and VRR-24 as evaluated in TER Sections 3.2.2.4, 3.5.1.4, and 3.7.1.4 respectively, pursuant to 10 CFR 50.55a(a){3){ii).
As discussed in these TER sections, the proposed alternative of disassembly and inspection of the applicable check valves was not determined acceptable for long-term relief because testing by other means appears to be practical. However, immediate imposition of the Code requirements would be an undue burden on the licensee in that the other means of performing testing of these valves are not currently in plant procedures, testing may require instrumentation which is not currently available, and immediate testing would require plant shutdown to perform. Additionally, the licensee may be aware of conditions not described in the relief request which further justify the proposed alternative, necessitating resubmittal of the relief requests.
To immediately impose the Code requirements would not provide a compensating increase in quality and safety. Generic Letter 89-04, Position 2, and
- Operations and Maintenance Standard OM-10, "lnservice Testing of Valves in Light-Water Reactor Power Plants," which is referenced as alternative rules in the 1989 Edition of Section XI.. allow the use of disassembly and inspection of check valves when testing is not practical. To require the immediate testing of the subject check valves by other means would be adverse to safety in that requiring a plant shutdown to perform testing challenges systems and components during the shutdown and subsequent startup process. Because the alternative is acceptable for valves when other means are not practical, there is not an increase in quality and safety for an interim period by requiring the licensee to immediately implement the other testing. The interim period of one year, or until the end of the next refueling outage, whichever is later, provides a sufficient period of time for the licensee to develop other testing means, or provide additional justification for relief if information supports further review, while not exceeding a period of time deemed adverse to quality and safety, and does not require plant shutdown solely to perform testing of these check valves.
Therefore, interim relief is granted as recommended in the TER for relief requests VRR-19, VRR-18, and VRR-24 pursuant to 10 CFR 50.55a(a}(3}(ii).
Immediate imposition of the Code requirements is a hardship without a compensating increase in the level of quality and safety as described above.
2.5 Relief Request VRR-25 Interim relief is recommended for Relief Request VRR-25 to allow a period of time for the licensee to develop testing methods and procedures necessary to comply with Code requirements.
The subject valves are feedwater flow regulating valves.
The relief request states that the valves are not required to go to the full open or closed position for plant safety. The TER discusses that these valves are normally closed and serve a safety function in both the open and closed positions. Generally, valves that function only as regulating valves are exempted from Section XI (IWV-1200).
However, if these regulating valves have a fail-safe function, or a function other than regulating feedwater flow,Section XI testing is required for monitoring the valves for degradation.
The valves are currently tested periodically per plant Technical Specifications by ensuring a flow of 165 gpm to each steam generator. If the valves have a fail-safe function, or another safety function to open or close, the current testing does not meet the intent of Section XI to monitor for degrading conditions; therefore, relief as requested cannot be granted for the long-term. Stroke.time testing provides an indication of degradation if increasing trends are identified. If stroke time testing is not practical for these valves due to design limitations, such as lack of position i-ndication, some other method must be developed.
Means to measure a change in system parameters may accomplish the intent, or a nonintrusive method may be required.
Any of these other methods will take a period of time to investigat~ and implement, and immediate imposition of the Code requirements would require that the system be declared inoperable until testing could be completed. This would result in exceeding a limiting condition of operation for the auxiliary
- - - - - - feedwater system and require a plant shutdown.
This would challenge plant systems and components during the shutdown and subsequent startup process, and rather than increasing safety for the short-term would be adverse to safety.
The current testing verifies the operational readiness of these valves for the interim period of one year, or until the end of the next refueling outage, whichever is later, while not requiring a plant shutdown solely to perform testing, and therefore, not adversely impacting quality and safety of the plant. Therefore, requiring the licensee to immediately comply with Code testing requirements for these valves would be a hardship with no compensating increase in quality or safety.
Therefore, interim relief is granted as recommended in the TER for relief request VRR-25 pursuant to 10 CFR 50.55a{a){3){ii).
Immediate imposition of the Code requirements is a hardship without a compensating increase in the level of quality and safety as described above.
3.0 CONCLUSION
The staff concludes that the relief requests as reviewed, evaluated, and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions.
The staff has determined that granting relief, pursuant to 10 CFR 50.55a (a)(3){i), {a){3){ii), or {g){6){i) is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination, the staff has considered the alternative testing being implemented, compliance resulting in a hardship without a compensating increase in safety, and the impracticality of performing the required testing considering the burden if the requirements were imposed.
The last column of Table l identifies the regulation or Generic Letter 89-04 guidance un~er which the requested relief is approved.
During the review of the licensee's inservice testing program, the staff has identified certain misinterpretations or omissions of 10 CFR 50.55a and Code requirements.
The items are summarized in this SEand the TER, Section 5.0.
The IST program relief r.equests for Palisades provided by the June 28, 1991, submittal are acceptable for implementation provided the changes and actions described in the SE and Section 5.0 of the TER are completed within one year of receipt of this SE, or by the end of the next refueling outage, whichever is 1 ater.